VA VOCATIONAL 

REHABILITATION 

AND EMPLOYMENT 

PROGRAM

Independent Living 

Services and Supports 

Require Stronger 

Oversight

Statement of Daniel Bertoni, Director

Education, Workforce, and Income Security

Testimony

Before the Subcommittee on Economic 

Opportunity, Committee on Veterans’ 

Affairs, House of Representatives

For Release on Delivery 

2:00 p.m. EST

Wednesday, November 13, 

2013

GAO-14-149T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-149T, a testimony 

before the Subcommittee on Economic 

Opportunity, Committee on Veterans’ Affairs, 

U.S. House of Representatives 

November 13, 2013

VA VOCATIONAL REHABILITATION AND 

EMPLOYMENT PROGRAM

Independent Living Services and Supports Require 

Stronger Oversight

Why GAO Did This Study

The IL track—one of five tracks within 

VA’s VR&E program—provides a 

range of non-employment related 

benefits to help veterans with serviceconnected disabilities live more 

independently when employment is not 

considered feasible at the time they 

enter the VR&E program. These 

benefits can include counseling, 

assistive devices, and other services or 

equipment. This testimony is based on 

GAO’s report issued in June 2013, and 

describes (1) the characteristics of 

veterans in the IL track, and the types 

and costs of benefits provided; (2) the 

extent to which their IL plans were 

completed, and the time it took to 

complete them; and (3) the extent to 

which the IL track has been 

administered appropriately and 

consistently across regional offices. 

GAO analyzed VA administrative data 

from fiscal years 2008 to 2011, and 

reviewed a random, generalizable 

sample of 182 veterans who entered 

the IL track in fiscal year 2008. In 

addition, GAO visited five VA regional 

offices; interviewed agency officials 

and staff; and reviewed relevant

federal laws, regulations, and agency 

policies, procedures, studies, and other 

documentation.

What GAO Recommends

In its June 2013 report, GAO 

recommended that VR&E explore 

options to enhance coordination with 

VHA, strengthen its oversight of the IL 

track, and reassess its policy for 

approving benefits. VA agreed with 

these recommendations.

What GAO Found

Of the 9,215 veterans who entered the Department of Veterans Affairs’ (VA) 

Independent Living (IL) track within the Vocational Rehabilitation and 

Employment (VR&E) program from fiscal years 2008 to 2011, most were male 

Vietnam era veterans in their 50s or 60s. The most prevalent disabilities among 

these veterans were post-traumatic stress disorder and tinnitus (“ringing in the 

ears”). GAO’s review of 182 IL cases from fiscal year 2008 shows that VR&E 

provided a range of IL benefits to veterans; the most common benefits being 

counseling services and computers. Less common benefits included gym 

memberships, camping equipment, and a boat. GAO estimates that VR&E spent 

nearly $14 million on benefits for veterans entering the IL track in fiscal year 

2008—an average of almost $6,000 per IL veteran. 

About 89 percent of fiscal year 2008 IL veterans were considered by VR&E to be 

“rehabilitated” by the end of fiscal year 2011; that is, generally, to have 

completed their IL plans. These plans identify each veteran’s independent living 

goals and the benefits VR&E will provide. The remaining 11 percent of cases

were either closed for various reasons, such as the veteran declined benefits, or 

were still active. Rehabilitation rates across regions varied from 49 to 100 

percent, and regions with larger IL caseloads generally rehabilitated a greater 

percentage of IL veterans. On average, IL plans nationwide were completed in 

384 days; however, completion times varied by region, from 150 to 895 days.

GAO identified four key areas where VR&E’s oversight was limited. First, some 

regions may not be complying with certain case management requirements. For 

instance, while VR&E is required to coordinate with the Veterans Health 

Administration (VHA) on IL benefits, VR&E counselors have difficulty obtaining 

timely responses from VHA. This has resulted in delayed benefits or VR&E 

providing the benefits instead of VHA. Second, VR&E does not systematically 

monitor regional variation in IL caseloads and benefits provided. Instead, it has

relied on its quality assurance reviews and ad hoc studies, but these are limited

in scope. Third, VR&E’s policies for approving IL expenditures may not be 

appropriate as regions were permitted to purchase a range of items without 

Central Office approval, some of which were costly or questionable. In one case 

GAO reviewed, Central Office review was not required for expenditures of 

$17,500 for a boat, motor, trailer, and the boat’s shipping, among other items. 

Finally, VR&E’s case management system does not collect information on IL 

costs and the types of benefits purchased. VR&E also lacks accurate data on the 

number of IL veterans served. While the law currently allows up to 2,700 

veterans to enter the IL track annually, data used to monitor the cap are based 

on the number of IL plans developed, not on the number of individual veterans 

admitted. Since veterans can have more than one IL plan in a fiscal year, one 

veteran could be counted multiple times towards the cap. VA plans to make 

modifications to its case management system to address this, but officials noted 

that it could take up to 3 years to obtain funding for this project.

View GAO-14-149T. For more information, 

contact Dan Bertoni at (202) 512-7215 or 

bertonid@gao.gov. 
Page 1 GAO-14-149T 

Chairman Flores, Ranking Member Takano, and Members of the 

Subcommittee:

I am pleased to discuss our recent work on the Department of Veterans

Affairs’ (VA) Vocational Rehabilitation and Employment Program’s 

(VR&E) Independent Living (IL) “track.”1 The IL track is one of five tracks 

administered by VR&E and provides non-employment related benefits—

such as counseling and assistive devices—to help veterans with serviceconnected disabilities live more independently when employment is not a 

feasible goal.2

Currently, there are 56 VA regional offices with responsibility for 

administering the IL track. Each office has a VR&E Officer who is 

responsible for ensuring compliance with national policies and 

performance standards, and for supervising Vocational Rehabilitation 

Counselors (VRCs) who work directly with veterans to assess their IL 

needs and provide benefits. The law allows VR&E broad discretion in 

determining the types of services that can be provided to address 

veterans’ IL needs.

In fiscal year 2011, almost 3,000 veterans nationwide were 

served through VR&E’s IL track.

3 When assessing each veteran, VR&E focuses not 

only on assisting veterans with activities of daily living,4 but also on their 

emotional needs and avocational and leisure interests, among other 

areas.5

 1

The VR&E program refers to each of the five possible courses of action it provides to 

veterans as a “track.”

An individualized IL plan, which is developed for each veteran 

admitted into the IL track, identifies the veteran’s IL goals, the goods and 

services VR&E will provide to help the veteran meet his or her goals, and 

estimated time frames for providing the goods and services, among other 

2 The other four tracks administered by VR&E are intended to help veterans prepare for, 

find, and maintain suitable employment. These tracks include (1) Reemployment, (2) 

Rapid Access to Employment, (3) Self-Employment, and (4) Employment Through LongTerm Services. 

3 Under 38 U.S.C. § 3120(d), a veteran’s IL program “shall consist of such services...as 

the Secretary determines necessary to enable such veteran to achieve maximum 

independence in daily living.” 

4 Activities of daily living are basic activities that individuals perform on a daily basis, such 

as bathing, feeding, and dressing themselves.

5 According to VA officials, IL services that support emotional needs and/or avocational 

and leisure interests may be included in IL plans only when gains in independence are an 

anticipated result.
Page 2 GAO-14-149T 

areas. In general, timeframes for IL plans may not exceed 24 months, 

except under certain circumstances.6 Under VA regulations, VR&E may 

declare a veteran successfully “rehabilitated” when all goals in their IL 

plan have been achieved, or if they meet other conditions.7 Therefore, 

“rehabilitation” does not necessarily mean that the veteran’s disabilities 

have improved, but rather that the goals developed in their IL plan to 

facilitate independence have been met. When veterans are not 

successfully rehabilitated, their case may be closed as “discontinued.”

VR&E can also temporarily “interrupt” a veteran’s case when 

circumstances arise that affect the provision of the goods and services. 

Because there is no statutory limit on the number of IL plans a veteran 

can have, officials told us that veterans can reapply to the VR&E program 

at any time and start another IL plan.8 However, unlike VR&E’s four 

employment-related tracks, the number of veterans who can be admitted 

into the IL track annually is limited by the law. While this number has 

increased over the years, the cap was set at 2,600 veterans in fiscal year 

2011, and 2,700 in fiscal year 2012.9

My remarks today are based on our report, which was released on June 

7, 2013, and describes (1) the characteristics of veterans in the IL track, 

 6 38 U.S.C. § 3105(d), 38 C.F.R. § 21.76(b). An additional period of 6 months is allowed if 

it would enable veterans to substantially increase their level of independence in daily 

living. In addition, VR&E may extend the duration up to 36 months for veterans with 

severe disabilities who served on active duty after September 11, 2001. 38 U.S.C. 

§ 3105(d)(2)(A)(ii) and Department of Veterans Affairs, Veterans Benefits Administration, 

Extension of Independent Living Services related to the Veterans Benefits Improvement 

Act of 2008 (Public Law 110-389), VR&E Letter 28-09-10 (January 30, 2009).

7 VR&E may declare a veteran successfully “rehabilitated” when all goals in their IL plan 

have been achieved, or if not all achieved, when the following three conditions have been 

met: (1) the veteran has attained a substantial increase in the level of independence; (2) 

the veteran has maintained the increased level of independence for at least 60 days; and 

(3) further assistance is unlikely to significantly increase the veteran’s level of 

independence. 38 C.F.R. § 21.283(e).

8 Specific criteria must be met before approving new plans for IL services. These criteria 

include meeting requirements for participation in a program of IL services, and the 

worsening of the veteran’s condition or other changes in the veteran’s circumstances 

resulting in a substantial loss of independence. 38 C.F.R. § 21.284(b).

9 The Veterans’ Benefits Act of 2010 increased the cap to 2,700 effective “with respect to 

fiscal years beginning after the date of enactment of this Act.” Pub. L. No. 111-275, § 801, 

124 Stat. 2864, 2888. Because the enactment date of the Act was October 13, 2010, 

which is in fiscal year 2011, the cap of 2,700 veterans would have become effective 

starting in fiscal year 2012.
Page 3 GAO-14-149T 

and the types and costs of benefits they were provided; (2) the extent to 

which their IL plans were completed, and the time it took to complete 

them; and (3) the extent to which the IL track has been administered 

appropriately and consistently across regional offices.10 To obtain this 

information, we reviewed relevant federal laws and regulations; standards 

for internal controls and managerial cost accounting; as well as VR&E 

policies, procedures, and other relevant studies and documentation. We 

also interviewed VA officials and veteran service organizations, and 

visited VA regional offices in San Diego, California; Atlanta, Georgia; 

Detroit, Michigan; Philadelphia, Pennsylvania; and the District of 

Columbia. In addition, we analyzed VA administrative data and used 

statistical models to determine any differences in rehabilitation times. 

Moreover, we reviewed the case files of a random, generalizable sample 

of 182 veterans who were assigned to the IL track at some point during 

fiscal year 2008. We conducted this work in accordance with generally 

accepted government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objectives. A more detailed explanation of our methodology is available in 

our report.

From fiscal years 2008 through 2011, the typical participant in the IL track 

was a male Vietnam-era veteran. Of the 9,215 veterans who entered the 

IL track in these years, most (67 percent) were male and 50 years old or 

older. Most women in the IL track were in their 40s or 50s. Most of the 

9,215 IL track veterans served in the Vietnam War; relatively few served 

in the Global War on Terrorism as part of Operation Enduring Freedom or 

Operation Iraqi Freedom.11

 10 GAO, VA Vocational Rehabilitation and Employment Program: Improved Oversight of 

Independent Living Services and Supports Is Needed, 

In addition, most (60 percent) IL track 

veterans served in the U.S. Army, and less than 1 percent served in the 

National Guard or Reserves. More than three-quarters of IL track 

veterans had a combined service-connected disability rating of at least 60 

GAO-13-474 (Washington, D.C.: 

June 7, 2013).

11 In fiscal year 2011, 46 percent of the 9,215 IL track veterans served in the Vietnam 

War, whereas 16 percent served in the Global War on Terrorism. 

The IL Track Mainly 

Serves Older Veterans 

and Provides a Wide 

Variety of Benefits
Page 4 GAO-14-149T 

percent, and 34 percent had a disability rating of 100 percent. Regardless 

of disability rating level, the most prevalent disabilities among this group 

were post-traumatic stress disorder (PTSD), tinnitus (“ringing in the 

ears”), and hearing loss.

Furthermore, our review of the case files of 182 randomly selected IL 

track veterans in fiscal year 2008 shows that they were provided a wide 

range of goods and services, from individual counseling and the 

installation of ramps to a boat, camping gear, and computers. The most 

common type of goods or services were related to counseling, education 

and training, and computer and camera equipment.12 For all veterans who 

entered the IL track in fiscal year 2008, we estimated that VR&E 

purchased a total of almost $14 million in goods and services. The 

average spent per IL track case that year was nearly $6,000.

We found that most (about 89 percent) of IL track veterans who began 

only one plan during fiscal year 2008 were classified by VR&E as 

“rehabilitated”—i.e., successfully reaching and maintaining the goals 

identified in their IL plan—by the end of fiscal year 2011. At the same 

time, about 11 percent of cases were either “discontinued”—i.e., closed 

by VR&E because the rehabilitation goals in the veteran’s IL plan were 

not completed—or were still active cases. Of the IL cases that had been 

discontinued, the reasons included the veteran declining benefits, not 

responding to VA’s attempts to contact them, worsening medical 

conditions, and death. We also found that some IL plans were easier to 

close as rehabilitated than others, due to the varied nature and 

complexity of IL plans, which are based on veterans’ individual disabilities 

and needs. For example, one IL plan we reviewed for a veteran with 

rheumatoid arthritis only called for the purchase and installation of eight 

door levers and a grab rail for the bathtub to facilitate his independence. 

However, another IL plan we reviewed called for providing a veteran who 

used a wheel-chair with medical, dental, and vision care as needed, and 

about $24,000 in modifications to the veteran’s home, including modifying 

the veteran’s bathroom, widening doors and modifying thresholds, and 

installing an emergency exit ramp in a bedroom.

 12 For a detailed list of goods and services provided to IL track veterans, see 

GAO-13-474.

Most Veterans Were 

“Rehabilitated” but 

within Varying Time 

Frames
Page 5 GAO-14-149T 

While the overall IL rehabilitation rate nationwide was 89 percent for 

veterans who started an IL plan in fiscal year 2008, the rate varied by 

regional office, from 49 to 100 percent.13 About two-thirds of regional 

offices rehabilitated 80 percent or more of their 2008 IL track veterans by 

the end of fiscal year 2011. In addition, VR&E’s IL rehabilitation rate was 

higher in regional offices with larger IL caseloads. Among veterans who 

entered the IL track in fiscal year 2008, an average of 90 percent were 

rehabilitated at offices with more than 25 IL entrants, compared to an 

average of 79 percent at offices with 25 or fewer IL entrants.14

Furthermore, in fiscal year 2008 IL veterans nationwide completed their IL 

plans in an average of 384 days (about 13 months); however, we found 

that the length of time to rehabilitate these veterans varied by regional 

office from a low of 150 days at the St. Paul Regional Office to a high of 

895 days at the Roanoke Regional Office.15 At most regional offices (49 

of 53), however, the average number of days to complete veterans’ IL 

plans ranged from 226 to 621 days (8 to 21 months).16 To control for 

various factors that could influence rehabilitation time frames, we used a 

statistical model to estimate the amount of time it would take certain 

groups of IL track veterans to complete their IL plans.17

 13 We excluded the Washington D.C. Regional Office—now referred to as the National 

Capital Region Benefits Office—because only two veterans entered the IL track during 

fiscal year 2008. One IL case was discontinued, and the other was open at the end of 

fiscal year 2011.

The results of our 

model show differences across regional offices in the amount of time it 

takes for veterans to become rehabilitated based on caseload. More 

specifically, the chance of rehabilitation within 2 years was less than 50 

percent at 4 offices, between 50 and 90 percent at 18 offices, and 90 

14 Twenty-six regional offices had more than 25 veterans enter the IL track during fiscal 

year 2008, while 30 offices had 25 or fewer veterans enter the IL track during the same 

time period. Two offices had no IL track entrants that year.

15 The St. Paul Regional Office had nine veterans enter the IL track during fiscal year 

2008, while the Roanoke Regional Office had two veterans enter that year.

16 We reported the average time to complete IL plans for 53 of VA’s 56 regional offices 

because two offices did not have veterans begin the IL track in fiscal year 2008. Another 

office had two IL track veterans begin during this period, but these veterans were not 

“rehabilitated.” 

17 Our model controlled for type and severity of disability and other demographic 

characteristics, among other factors. For additional information on the methodology we 

used for our statistical analysis, see our report (GAO-13-474).
Page 6 GAO-14-149T 

percent or higher at 16 offices. Veterans served by regional offices with 

large IL caseloads generally had a higher probability of completing an IL 

plan more quickly than a veteran served by an office with a small IL 

caseload (see fig 1).

Figure 1: Estimated Probability of a Veteran Completing an Independent Living Plan 

within Certain Time Periods, by Regional Office Based on Caseload

Note: Estimates were calculated from a statistical model. See GAO-13-474 for more information on 

our methodology.

We identified four key areas where VR&E’s oversight of the IL track was 

limited: (1) ensuring compliance with case management requirements, (2) 

monitoring regional variation in IL track caseload and benefits provided, 

(3) adequacy of policies and procedures for approving expenditures on 

goods and services for IL track veterans, and (4) availability of critical 

program management information.

VR&E Exercises 

Limited Oversight of 

the IL Track
Page 7 GAO-14-149T 

Certain VR&E case management requirements were not being met by 

some regional offices. For example, based on our review of VR&E’s site 

visit monitoring reports, we found that some Vocational Rehabilitation 

Counselors (VRCs) were not fulfilling VR&E’s requirement to meet inperson each month with IL track veterans to monitor progress in 

completing their IL plans.18 VRCs told us that this requirement is a 

challenge due to the size of their caseloads and the distances that they 

may have to travel to meet with veterans. Furthermore, while VR&E and 

the Veterans Health Administration (VHA) both have policies that require 

them to coordinate on the provision of goods and services for IL track 

veterans, we found that some VRCs experience challenges in doing so.19

Several VRCs in the regions we interviewed indicated that when they 

refer IL track cases to VHA physicians, the physicians do not respond or 

they respond too late. As a result, services for IL track veterans are 

delayed or purchased by VR&E instead of VHA. In our review of 182 IL 

track case records, we found some instances where VR&E purchased 

goods and services that appear to be medically related, such as ramps 

and grab bars, which could have been provided by VHA. In response, we 

recommended VA explore options for enhancing coordination to ensure IL 

track veterans’ needs are met by VHA, when appropriate, in a timely 

manner. VA concurred and stated that it was piloting an automated 

referral system that would allow VR&E staff to make referrals to VHA 

providers and check on their status electronically.

 18 VR&E’s policy manual states that contact via telephone, email, or mail can be used as 

alternatives when necessary. Department of Veterans Affairs, Vocational Rehabilitation 

and Employment, Chapter 9: Guidelines for the Administration of An Independent Living 

Plan, VR&E manual, Part IV, Section C, Chapter 9.

19 Specifically, VA regulations governing VR&E’s IL track require that if a veteran needs 

special equipment and is eligible for such equipment under another VA program, the items 

will be provided under that program. See 38 C.F.R § 21.216(b). In addition, VHA’s policy 

directive for coordinating with VR&E is intended to ensure that all VR&E participants, 

including those in the IL track, receive timely access to VHA health care services. See 

Department of Veterans Affairs, Veterans Health Administration, VHA Directive 2010-022, 

Vocational Rehabilitation: Chapter 31 Benefits, Timely Access to Health Care Services 

(May 14, 2010).

Regional Offices May Not 

Be Complying with VR&E 

Case Management 

Requirements
Page 8 GAO-14-149T 

VR&E does not systematically monitor variation in IL track caseload size 

and benefits across its regional offices. We found that the total IL track 

caseload for fiscal years 2008 through 2011 ranged from over 900 cases 

in the Montgomery, Alabama Regional Office to 4 cases in the 

Wilmington, Delaware Regional Office. In addition, we found that some 

regions developed IL plans that addressed a broad range of needs while 

others elected to develop more focused plans that provided fewer 

benefits to achieve VR&E’s rehabilitation goal. VR&E has relied on the 

information provided through its general quality assurance (QA) 

activities20 and a series of periodic ad hoc studies to oversee the 

administration of the IL track. Because these activities are limited in 

scope, frequency, and how the information is used, we noted that they 

may not ensure consistent administration of the IL track across regions. In 

response, VR&E officials commented that QA results are analyzed to 

determine trends, and make decisions about training content and 

frequency.

VR&E’s current policy for approving IL track expenditures may not be 

adequate, considering the broad discretion VR&E provides to regions in 

determining and purchasing goods and services. While officials told us 

that VRCs are required to include all cost estimates when they submit 

veterans’ IL plans to be reviewed and approved by the region’s VR&E 

Officer, VR&E’s written policy and guidance do not explicitly require this 

for all IL expenditures. Thus, regional offices have the ability to purchase 

a broad range of items without any Central Office approval, resulting in 

some offices purchasing goods and services that may be questionable or 

costly. (See table 1 for the level of approval required for IL expenditures.) 

In one case we reviewed, VR&E Central Office approval was not required 

for the purchase of a boat, motor, trailer, and the boat’s shipping cost, 

among other items, totaling about $17,500. In another case we reviewed, 

VR&E Central Office was not required to approve total expenditures of 

$18,829 for a riding lawn mower—which VR&E’s current policy 

 20 A team of VR&E QA staff at the national level perform periodic site visits to each VA 

regional office at least every 3 years, although officials told us they have not been able to 

meet this goal in recent years because of budgetary constraints. This team also 

periodically reviews a sample of veterans’ records from VR&E’s IL and employment tracks 

in selected regions, and produces a report for the particular region under review.

VR&E Does Not 

Systematically Monitor 

Variation in IL Caseload 

and Benefits Provided

VR&E’s Policy for 

Approving IL Track 

Expenditures May Not Be 

Adequate
Page 9 GAO-14-149T 

prohibits21—and other IL goods and services including a bed, bed frame, 

desktop computer, and woodworking equipment. Without appropriate 

approval levels, VR&E’s IL track may be vulnerable to potential fraud, 

waste, and abuse.22

Table 1: Level of Approval Required for Construction and Non-ConstructionRelated Expenditures in Independent Living Track Cases

In our report, we recommended that VA reassess 

and consider enhancing its current policy concerning the required level of 

approval for IL track expenditures. VA concurred with our 

recommendation and said it will use the results of an internal study to 

determine if changes are needed to its existing cost-review policies or 

procedures. VA stated that any necessary changes should be 

implemented by March 2014.

Required level of 

approval 

Construction-related 

expenditures 

Non-construction related 

expenditures 

No supervisory approval 

required

Less than $2,000 a Less than $25,000 

Regional VR&E Officer $25,000 to less than $75,000 

Regional Office Director $2,000 through $25,000 $75,000 through $100,000 

VR&E Central Office More than $25,000 More than $100,000 

Source: GAO analysis of VA policies.

a VR&E officials told us that all IL plans require supervisory review. However, VR&E’s written policies 

do not require IL expenditures to be reviewed and approved by the VR&E officer unless they meet 

certain cost-thresholds.

 21 While officials told us that the provision of riding lawn mowers was not specifically 

prohibited by VR&E’s policy in 2008, its current policy states that tractors or mowers 

should not be approved as a mobility aid. See Department of Veterans Affairs, Veterans 

Benefits Administration, Purchase of Vehicles for Vocational Rehabilitation & Employment 

(VR&E) Participants under 38 U.S.C. Chapter 31 is prohibited, VR&E Letter 28-13-08 

(November 6, 2012). 

22 To guard against fraud, waste, abuse, and mismanagement, standards for internal 

control in the federal government emphasize the need for agencies to have appropriate 

levels of supervision and controls in place to prevent one individual from having 

responsibility for all key aspects of a transaction or event. GAO, Internal Control 

Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.: August 2001).
Page 10 GAO-14-149T 

VR&E’s case management system—commonly referred to as 

“CWINRS”23

• Costs of IL goods and service purchased: The system does not collect 

information on the total amount of funds VR&E expends on IL 

benefits. VR&E aggregates costs across all its tracks, despite VA’s 

managerial cost accounting policies that require the costs of products 

and services to be captured for management purposes.

—does not collect or report critical program management 

information that would help the agency in its oversight responsibilities. 

More specifically, this system does not collect and maintain information 

on:

24 Federal 

financial accounting standards also recommend that costs of 

programs be measured and reported.25 According to VA officials, cost 

information is not collected on the IL track alone because they view 

the five tracks within VR&E as a single program with the same 

overarching goal—to help veterans achieve their employment goals. 

We previously reported on this issue in 2009. At that time, we found 

that VR&E’s five tracks do not share the same overarching goal. 

Therefore, we concluded that VR&E should not combine track 

information.26

 23 VR&E has used the CWINRS system since 2001 to track veteran cases through its 

process and to manage program costs. The “WINRS” part of the acronym represents the 

first 5 regional offices that tested the original system. These offices include Waco, Texas; 

Indianapolis, Indiana; Newark, New Jersey; Roanoke, Virginia; and Seattle, Washington.

24 VA’s policy states that managerial cost accounting should be performed to measure 

and report the costs incurred by the agency. Specifically, each administration and its units 

should identify the cost of products and services provided. The goal of this effort is to 

identify the product or service at the level in which it is rendered to an external customer, 

such as a veteran receiving benefits from a VA program. Department of Veterans Affairs 

Managerial Cost Accounting: VA Financial Policies and Procedures, volume III, chapter 3 

(July 2010).

25 Managerial cost accounting is a fundamental part of an agency’s financial management 

system, and each agency and its units should report the costs of their activities on a 

regular basis. This cost information can be used by Congress and federal executives in 

making decisions about allocating federal resources, authorizing and modifying programs, 

and evaluating performance. The cost information can also be used by program managers 

in making managerial decisions to improve operating economy and efficiency. Statement 

of Federal Financial Accounting Standards 4: Managerial Cost Accounting Standards and 

Concepts.

26 GAO, VA Vocational Rehabilitation and Employment: Better Incentives, Workforce 

Planning, and Performance Reporting Could Improve Program, GAO-09-34 (Washington, 

D.C.: January 26, 2009).

VR&E Lacks Critical IL 

Track Information for 

Oversight
Page 11 GAO-14-149T 

• Types of IL benefits provided: The system does not collect information 

on the types of IL benefits provided to veterans in a standardized 

manner that can be easily aggregated and analyzed for oversight 

purposes. In several of the IL track cases we reviewed, the goods and 

services purchased were grouped together under a general 

description, such as “IL equipment” or “IL supplies,” without any 

further details. In addition, we found that controls for data entry were 

not adequate to ensure that all important data were recorded.27 For 

example, we estimated that the service provider field was either 

missing or unclear for one or more services in about 15 percent of all 

IL cases that began in fiscal year 2008.

• Number of IL veterans served: The system does not provide VR&E 

with the information it needs to monitor its statutory entrant cap and 

program operations. The law allows VR&E to initiate “programs” of 

independent living services and assistance for no more than a 

specified number of veterans each year, which, as of 2012, was set at 

2,700.28

Similar to our report’s findings, VR&E’s 2012 evaluation of CWINRS has 

shown that the system limits VR&E’s oversight abilities and does not 

capture all important data elements to support the agency’s “evolving 

In analyzing VR&E’s administrative data, we found that 

VR&E counts the number of IL plans developed annually rather than

the number of individual veterans admitted to the track. Because 

multiple IL plans can be developed for an individual veteran during the 

same fiscal year, veterans with multiple plans may be counted more 

than once toward the statutory cap. As a result, VR&E lacks complete 

information on the number of veterans it is serving through the IL track 

at any given time—information it could use to better manage staff, 

workloads, and program resources, and ensure that it can effectively 

manage its cap.

 27 Standards for internal control emphasize the need to have controls over computerized 

information systems to ensure the data entered is complete and accurate 

(GAO-01-1008G). In addition, GAO’s federal information system controls audit manual 

states that agencies should establish procedures to provide reasonable assurance that all 

inputs into the application have been authorized, accepted for processing, and accounted 

for; and any missing or unaccounted for source documents or input files have been 

identified and investigated. GAO, Federal Information System Controls Audit Manual 

(FISCAM), GAO-09-232G (Washington, D.C.: February 2009).

28 38 U.S.C. § 3120(e). According to agency officials, “IL plans” are the same as 

“programs” of independent living services and assistance.
Page 12 GAO-14-149T 

business needs.”29

In conclusion, strengthening oversight of VR&E’s IL track is imperative 

given the wide range of goods and services that can be provided under 

the law to help veterans with service-connected disabilities improve their 

ability to live independently when employment is not feasible. More 

attention at the national level can help ensure that IL track case 

management requirements are met, the track is administered consistently 

across regions, expenditures for goods and services are appropriate, and 

critical information is collected and used to ensure veterans’ IL needs are 

sufficiently addressed.

Officials told us that they plan to modify CWINRS, and 

that the new system modifications will enable them to individually track 

veterans served through the IL track. However, we found that the 

CWINRS redesign will not enable VR&E to obtain data on IL track 

expenditures or the types of goods and services provided. At the time of 

our review, no specific time frames were provided for the CWINRS 

redesign, but officials noted it could take up to 3 years to obtain funding 

for this effort. In our report, we recommended that VA implement an 

oversight approach that enables VR&E to better ensure consistent 

administration of the IL track across regions. This approach would include 

ensuring that CWINRS (1) tracks the types of goods and services 

provided and their costs, (2) accounts for the number of IL track veterans 

being served, and (3) contains stronger data entry controls. VA concurred 

with our recommendation and stated that discussions of system 

enhancements and the development of ad hoc reports are ongoing. The 

agency also will be considering a new oversight approach as part of an 

internal study.

Chairman Flores, Ranking Member Takano, and Members of the 

Subcommittee, this concludes my prepared remarks. I would be happy to 

answer any questions that you or other members of the subcommittee 

may have.

 29 Department of Veterans Affairs, Vocational Rehabilitation and Employment (VR&E) 

Case Management Portal Project, Version 1.0, Case Management Portal, Business 

Requirements Document (September 26, 2012).
Page 13 GAO-14-149T 

For further information regarding this testimony, please contact Daniel 

Bertoni at (202) 512-7215, or at bertonid@gao.gov. Contact points for our 

Office of Congressional Relations and Public Affairs may be found on the 

last page of this statement. Individuals who made key contributions to this 

testimony include Clarita Mrena (Assistant Director), James Bennett, 

David Chrisinger, David Forgosh, Mitch Karpman, Sheila McCoy, James 

Rebbe, Martin Scire, Ryan Siegel, Almeta Spencer, Jeff Tessin, Jack 

Warner, and Ashanta Williams.

Contacts and Staff 

Acknowledgments

(131285)
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